Epstein Secrets

ed, the Eleventh Circuit has clearly held that the manner in which an agreement is formed can render an otherwise-valid agreement unenforceable. In San Pedro v. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in order for any provision in a plea agreement to be enforceable, "t

pstein. The facts of San Pedro offer clear parallels to this case. There, the prosecutor offered a promise of non-deportation to criminal defendant San Pedro. The Eleventh Circuit concluded that this agreement was unenforceable, because by statute the power to enforce immigration laws rested with the Imm

se) that Epstein's legal team had no knowledge whatsoever that the Government was violating its CVRA obligations. A helpful case is United States v. Walker, 98 F.3d 944 (7th Cir. 1996). 55 EFTA00021499 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 59 o

ed, the Eleventh Circuit has clearly held that the manner in which an agreement is formed can render an otherwise-valid agreement unenforceable. In San Pedro v. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in order for any provision in a plea agreement to be enforceable, "t

v-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 27 of 70 United States Attorney and the AUSAs who negotiated the plea agreement with San Pedro did not have the authority to promise that he would not be deported." Id. at 1072. So too here. Prosecutors were simply not authorized to offer Eps

se) that Epstein's legal team had no knowledge whatsoever that the Government was violating its CVRA obligations. A helpful case is United States v. Walker, 98 F.3d 944 (7th Cir. 1996). 55 EFTA00022603 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 59 o

h amendment right — not an alleged victim's — to insist that the defendant be represented by conflict-free counsel; c) rely heavily on the case of San Pedro v. United States, 79 f.3d 1065, 1068 (11" Cir. 1999) (DE 466:24-25, 38), an easily distinguished case not cited by Petitioners in their initial sub

to respond; g) mischaracterize Mr. Epstein's discussion of the Walke• case (DE 464:55-56), inasmuch as it was not the Seventh Circuit's ruling in Walker that Mr. Epstein claimed was "entirely confused," but rather the Petitioners' discussion of it in their initial submission. (DE 463:25); and h) a